Legal

Privacy Policy

Last updated: February 2026

1. Data Controller

Wicflow
Business ID (Y-tunnus): 3590597-7
Helsinki, Finland
Contact: felix@thescalingschool.com
WhatsApp: +358 44 305 2209

2. What Data We Collect

We collect the following data when you interact with our website and services:

Contact information: Name, email address, phone number, and company name when you book a call, fill out a form, or contact us via WhatsApp.

Chatbot conversations: Messages you send through our website chatbot (Felix) to provide responses and improve our service.

Website analytics: Anonymous usage data via Google Analytics (pages visited, time on site, device type, approximate location). We do not track individual users.

Booking information: When you schedule a call through our booking system, we collect the information you provide (name, email, phone number, preferred time).

3. How We Use Your Data

We use your data to:

• Respond to your inquiries and provide our services
• Schedule and conduct assessment calls
• Improve our website and chatbot functionality
• Send you information about our services (only if you've opted in)
• Understand how visitors use our website (anonymous analytics)

We do not sell your data to third parties. We do not use your data for automated decision-making or profiling.

4. Data Storage and Security

Your data is stored exclusively in EU data centers (Frankfurt, Amsterdam). We use enterprise-grade encryption for data in transit and at rest.

Our infrastructure is hosted on AWS and Google Cloud with EU data residency. Access to customer data is restricted to authorized team members only.

5. Third-Party Services

We use the following third-party services that may process your data:

Google Analytics — Website analytics (anonymous data)
LeadConnector/GoHighLevel — Booking system and CRM
OpenAI — Powers our chatbot (conversations processed via API, not used for model training)
WhatsApp (Meta) — When you contact us via WhatsApp

All third-party services are selected for GDPR compliance and EU data residency where available.

6. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the right to:

Access your personal data we hold
Rectify inaccurate personal data
Erase your personal data ("right to be forgotten")
Restrict processing of your personal data
Data portability — receive your data in a structured format
Object to processing of your personal data
Withdraw consent at any time

To exercise any of these rights, contact us at felix@thescalingschool.com. We will respond within 30 days.

7. Cookies

Our website uses Google Analytics cookies to understand how visitors use the site. These cookies collect anonymous data and do not personally identify you.

Our chatbot uses local storage to maintain your conversation within a session.

8. Data Retention

We retain your contact information for as long as we have a business relationship or legitimate interest. Chatbot conversation data is retained for up to 12 months for service improvement. You can request deletion of your data at any time.

9. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto):

Office of the Data Protection Ombudsman
Lintulahdenkuja 4, 00530 Helsinki
tietosuoja.fi

10. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated "last updated" date.